ALEXANDER v. GREYSTAR
2:25-cv-03300
E.D. Pa.Jul 2, 2025Background
- Liam Alexander, a Pennsylvania resident, filed a pro se complaint against his landlord, Greystar, a Pennsylvania corporation.
- Alexander alleged that Greystar breached their contract and illegally evicted him, seeking $5 million in damages and injunctive relief.
- He filed for leave to proceed in forma pauperis (without paying court fees).
- The Complaint invoked federal question and diversity jurisdiction, but only referenced state-law claims (breach of contract and eviction).
- Both parties are citizens of Pennsylvania, and no federal law basis was asserted in the Complaint.
- The court sua sponte considered subject matter jurisdiction before addressing the merits of Alexander's claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the court have federal question jurisdiction? | Alexander checked the box for federal law claims; wrote “443 Housing” | Not stated (no answer yet filed) | No federal law basis pled; jurisdiction lacking |
| Does the court have diversity jurisdiction? | Alexander claims parties are diverse | Not stated | Both parties are PA citizens; no diversity |
| Does the complaint state a federal cause of action? | Complaint alleges breach of contract/eviction | Not stated | No plausible federal claim alleged |
| Can the complaint proceed as pled? | Alexander seeks court protection and damages | Not stated | Dismissed for lack of subject matter jurisdiction |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standard for plausibility of claims at pleadings stage)
- Lincoln Ben. Life Co. v. AEI Life, LLC, 800 F.3d 99 (3d Cir. 2015) (party alleging subject-matter jurisdiction bears the burden of proving it)
- Zambelli Fireworks Mfg. Co. v. Wood, 592 F.3d 412 (3d Cir. 2010) (section 1332(a) requires complete diversity for jurisdiction)
- Lincoln Prop. Co. v. Roche, 546 U.S. 81 (2005) (diversity jurisdiction demands no plaintiff is a citizen of same state as any defendant)
- Krasnov v. Dinan, 465 F.2d 1298 (3d Cir. 1972) (residency vs. domicile in evaluating citizenship for diversity jurisdiction)
